Effective Date: March 2021
This Policy is governed by the European and French legislation on personal data protection, including the Regulation (EU) 2016/679 of 27 April 2016 (the “GDPR”) as well as the French Data Protection Act no. 78-17 of 6 January 1978 modified by the French act n°2018-493 of 20 June 2018, including any future amendments updates and revisions thereto (altogether “Data Protection Laws”). For the purpose of this Policy, the terms “personal data”, “process”, “data processor”, “data controller”, “data protection authority” shall have the meaning defined in Article 4 GDPR.
Pursuant to the GDPR, Privowny is the data controller with respect to any personal data collected and processed as part of provided services or in connection with our Website.
1. Personal Data we collect
- Name and surname;
- Email address;
- Company name;
- Business function;
- The message you left on the “Contact” page and/or the content of your email (including attachments)
We also collect technical data relating to your use of the Website, notably including the IP address (collected automatically when you access the Website).
We collect your personal data when you visit and otherwise use the Website, as specified above, when you provide us with such information using electronic or hard copy forms, contact us by telephone, fax, email, post or via the “Contact” page or any other mean.
2. Why and on which basis do we collect personal data?
Privowny collects, uses and stores your personal data on the basis of legitimate interest, in order to:
- provide you with the Service on our Website,
- conduct our business functions and activities,
- improve and ensure the security of our Website,
- improve and customize our Website as well as products and services we provide,
- provide you with information, products and services that you request from us,
- provide you with a bug report,
- collect data of candidates,
- communicate with media and press services,
- comply with our legal obligations,
- and for other legitimate purposes permitted by Data Protection Laws.
If you specifically agreed to it, Privowny collects, uses and stores your personal data to send direct marketing and other communications related to our business, products and services.
3. Data retention
We store your personal data for as long as necessary to provide you with the services you have requested, or for other purposes such as complying with our legal obligations, resolving disputes and enforcing the agreements to which Privowny is a party.
Please note that Privowny is required by applicable law and/or regulations to retain some types of information for certain periods of time (e.g. statute of limitations). If your personal data is no longer necessary with respect to purposes for which it is processed and Privowny has no legal obligation to retain it, subject to the prior exercise of your right to deletion, we will erase it from our systems and destroy all record of it.
|Relevant Personal Information||Retention Period|
|Contact Data||3 years from data collection or last contact with you|
|Data related to measurement of the traffic and personalization of the Website, managing cookies||13 months|
|Data related to requests to access or rectify data, or oppose data processing||3 years from your request|
|Data related to potential employees||2 years from last contact with candidate|
4. Cookies and trackers
Privowny uses trackers which aim to track your use of the Website. Our goal is to verify that your use of the Website is optimal and to be able to improve the Product. We do not use these trackers to send you advertising.
Privowny uses a tool called “Countly” for its usage statistics. All data is hosted by Privowny, Countly does not have access to personal statistical data. This tool uses “localStorage” rather than cookies when it can (i.e., when you use the default options of the majority of internet browsers).
LocalStorage has the same function as cookies (storing connection / activity information), but does not use the same technical tools. As the name suggests, the content of localStorage can be read on the client side (i.e., on your browser) while the content of cookies can be read on the server side. LocalStorage has no information retention period, it depends on your browser settings or on the “clear cache” action.
To establish these usage statistics, Countly will deposit localStorage or cookies that collect your IP address, deprecated to keep only your city, as well as the device and the browser you use.
Privowny does not share this information with third parties. Our trackers are only enabled on our websites (i.e., our Countly trackers do not follow you on other websites).
5. Sharing your personal data
Privowny protects your privacy. As a result, we do not sell or rent or otherwise share any of your personal data with third parties for advertising or commercial purposes. We only disclose your personal data to third-party processors and vendors that provide products and services to us, or to other third parties where expressly instructed by you, as the case may be.
In this respect, we only use carefully vetted third-party processors and vendors, located inside or outside of the European Union territory, to provide us with certain products or services. Our third-party data processors are compliant with the GDPR, in particular with respect to data security and confidentiality, and only process your personal data on our behalf and under our written instructions in order to offer the contracted services to Privowny.
Please find here the list of our processors:
|Processor||Aim||Personal data we collected||Contact|
|Amazon Web Services||Hosting our platform||What you write on the “Contact” page||Data Protection Officer
Amazon Web Services - EMEA SARL
38 Avenue John F. Kennedy
|Datadog||Hosting our logs||All logs, which may contain personal data such as your IP address, an identifying number and your email@example.com|
6. Transfer of your personal data outside of the EU/EEA
A Transfer may occur if our processors and/or vendors are located outside of the EU/EEA, if we outsource certain activities outside of the EU/EEA or if you use the Website in a country located outside of the EU/EEA.
Where required by applicable privacy and Data Protection Laws, we take steps in order to ensure any Transfer is performed in compliance with the appropriate organizational and technical means (including e.g. European Commission’s standard contractual clauses for data transfers, or European Commission’s adequacy decisions).
7. Your rights
Under the GDPR, you have rights that apply to your personal data, including right to access, rectify, erase, restrict or object to data processing, or have the personal data that we hold about you ported to another data controller or service provider.
You can request to access and receive a copy of the personal data that we hold about you at any time.
Under certain circumstances provided by Data Protection Laws, we may deny you such access. If we refuse your request to access your personal information, we will provide you with reasons for the refusal where we are required by Data Protection Laws to disclose those reasons.
Privowny uses its best efforts to ensure that any personal information we collect and hold is accurate, complete and up-to-date. In this respect, you undertake to provide us with true, accurate, current and complete information about yourself as requested, and properly update the information provided to us so that it remains accurate, complete and up-to-date at all times.
Alternatively, please notify us regarding any change that applies to the personal data you provided us with, notably by contacting us using the details provided below if you believe that the personal information is inaccurate or incomplete, and we will correct the information.
8. Security and confidentiality
Privowny values your privacy and use its utmost efforts to warrant the security and confidentiality of any information you may provide us with. Consequently, we implemented appropriate technical and organizational measures to ensure that personal data we hold, whether in hard copy or on our computer systems, remains protected at any time against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access.
Privowny France SAS
Parc du Golf Bâtiment 20 Safran, 350 avenue JRGG de la Lauzière,
In case of dispute, you, or an association you designated for this purpose, as provided by Data Protection Laws, have the right to lodge a complaint to a competent data protection authority such as the French Data protection agency (CNIL - cnil.fr.)
A complete list of all the European Data Protection Authorities and how to contact them is available at: https://edpb.europa.eu/about-edpb/board/members_en
10. Notice to California consumers
Under the California Consumer Privacy Act of 2018 (“CCPA”), all California consumers have the following rights towards their personal information:
- right to notice
- right to access
- right to request deletion
- right to opt-out
- right to equal services and prices
The “right to equal services and prices” prohibits businesses from discriminating against consumers who exercise their CCPA rights. Today, our services are free.